I
am directed to refer the letter No: - A.11019/25/2011/MF. CGA (A)/AICAEA-HQ/413
dated 09.03.2015 of your office on the above mentioned subject and state that,
we have submitted a joint Memorandum to the JS(Pers), Department of Expenditure
with the request of granting appropriate replacement pay scales vide our letter
No:- AICAEA/HQ/A-42/7thCPC2015/ dated 28.12.2015.

In
this connection, I would like request you to kindly refer the discussion held between
us on 11.12.2015 in your chamber and forward our representation with your
recommendations to the Implementation Cell constituted by the Government for
examining and implementing the 7CPC recommendations.

We
shall be thankful if a copy your recommendation letter is endorsed to this
Association for its further necessary action.

Subject:
-Memorandum on the recommendations of the 7th CPC in respect of the
employees and officers of Civil Accounts organization – request to grant
appropriate replacement pay level –Regarding.

Madam,

We on behalf of the above Associations
would like to refer your D.O. No. 1-4/2015-E.III (A) dated 21st
November 2015 and Controller General of Accounts, Ministry of Finance,
Department Expenditure letter No. A.11019/25/2011/MF.CGA(A)/AICAEA-HQ/413 dated
9th December 2015 and submit following few lines on the
recommendations of the 7 CPC with regard to pay scales of Accounts Cadres.

So far as common issues are concerned, we endorse the suggestions
and demands placed by the National Joint Council of Action vide letter No.
NJC/2015/7th CPC dated 10th December 2015 to Cabinet
Secretary to the Government of India.

We also endorse the letter No: JAC/2015/1/ 01 dated 11.12.2015 of
the
Joint Action Committee of Accounts and Audit Employees and Officers
organizations addressed to the Secretary, Department of Expenditure and request
that our following submissions may kindly be considered sympathetically leading
to rectification of the injustice done to the Accounts and Audit cadres through
the Empowered Committee that will look into the recommendations of 7 CPC.

1.Accounts/Audit
Assistant:

The Accounting and Auditing
Departments are not administrative offices and in these departments, all items
of work are of technical nature. Like administrative offices there is no method
of receiving dak/letters and dispatch of those in the Accounts Organization or
in any other departments of Accounts and Audit. Instead the existing persons
who are designated as LDCs in these departments are basically working in the
technical sections where they are handling the Bills, different types of
Accounts and Audit related documents, Bank Statements, Cheques/ Demand
Drafts/Bankers Cheques, Challans, receipt and payment vouchers, ledgers and
Broadsheets etc. After computerization,
their duties have become more complex, sophisticated and important as they are
to record those documents electronically, generate tokens and even process them
in the computers. Virtually the designated LDCs in the Accounts and Audit
Departments are discharging technical responsibilities and performing the
duties of Accounts Assistants.

In view of this, we requested the 7th CPC that the
cadre of LDC in the Audit and Accounting formations may be re-designated as
Accounts/Audit Assistants and recommend for grant of replacement scale of PB-1
Grade Pay Rs.2400. But 7CPC ignored the request and gave no comment on the
matter. The C&AG and other Departmental Heads of Organized Accounts have
recommended the same in the Memorandums submitted to the 7th CPC.

We therefore
request that the LDCs of Accounts and Audit organizations may be granted the
level 4pay scale of Table 5.Pay
Matrix.

2.Accountant/
Auditor:

The V
CPC distinguished the UDCs (designated as Senior Clerks) in the Ministerial
cadre of Railways and assigned higher Pay Scale of 4500-7000 (pre-revised Pay
Scale of 1400-2300) on the consideration that in the cadre of Senior Clerks there
was an induction (direct entry) of 1/3rd by the graduates whereas
UDCs of CSS & other offices were promotees from LDCs who were matriculates
only. The said Commission however did not recommend the Pay Scale of 4500-7000
for Auditors/Accountants in which cadre there was induction of graduates to the
extent of 50% to 80%.

Government
of India took note of this omission of V CPC and upgraded the Pay Scale of
Auditors/Accountants to 4500-7000 notionally with effect from 01.01.1996 and
actually with effect from 19.02.2003.In Para 7.56 of their Report for other
posts in IA&AD, the VI CPC had recommended that,

“The Commission has separately recommended Parity between
Secretariat and Non Secretariat Organizations in Chapter 3.1. of the Report
which will also extend to other posts in IA&AD.”

The VI CPC, conceding the
principle parity between Field and Secretariat office, had given the following
existing and revised pay structure in Field Organizations vide Table below Para
3.1.14 of VI CPC Report:

Post

Present Pay
Scale Recommended Pay Scale

Recommended

Pay
Band Grade Pay

Head
Clerk/Assistant

Steno Gr II &

Equivalent

4500-70006500-10500

5000-8000

PB-2 4200

The
term “Equivalent” invariably meant inclusion of Auditors/Accountants in the
field offices of IA&AD and Organized Accounts. This is very lucidly implied
from the fact that nowhere else the VI CPC had recommended the revised Pay Band
and Grade Pay for Auditors/Accountants.

In the light
of these, Auditors/Accountants should have been granted the Grade Pay of 4200
in PB-2 and not Grade Pay of 2800 in PB-1 by the Government which was
overlooked.

But the 7CPC
has rejected the demand for GP 4200, PB2 to Auditor/Accountant by inventing a
new baseless and irrational ground that, applicants who are appointed as
Accountant and Auditor in the CGLE examination of SSC which conducts the
written examination and interview for recruitments in the grade pay of 4600,
4200 and 2800 appear only written examination and not interview. This
proposition of 7 CPC was not only irrelevant but also totally wrong. There was
no decision of this nature of the government of India and the pay scale of
Accountant was never determined on this basis.
Moreover, the 7CPC had not also taken into account the fact that
continuation and further promotion ahead of the post of Accountant/ Auditor for
the applicants even after their regular appointment is dependent on the
clearing of Departmental Confirmatory Examination by them within a period of
two years and in four chances. 7CPC seems to be unaware of the fact that the increments
shall be available to the Accountants/Auditors only after qualifying in the
Departmental Confirmatory Examination by them.

7th CPC has examined the parity of
Pay scales with Assistance of CSS elaborately in the Chapter relating to
Ministry of Defence under Organised Accounts Staff heading in para 11.12.134, 135,
136 and 137. The Commission simply observed that,

“TheCommission,
in Chapter 7.1, has already taken a view with regard to pay, level of
Assistants of CSS. The recommendation there in settles the parities as have
been sought to be established.”

But in the
para 11.62.17 the 7CPC contradicted itself by stating that posts belonging to
two different services performing distinct functions cannot be treated at per
merely for the reason of being in identical pay scales at some point of time
and therefore, recommended normal replacement levels for the Senior Auditors/Accountants.

The 7CPC had adopted the most unscientific method to deal with the
pay parity issue with the Assistants of Central Secretariat. Assistants of
Central Secretariat have been brought down to level 6 in the Pay Matrix and
thus settling the parity claims of others. At the same time the Pay protection
is allowed to the Assistants already in the G.P. of Rs.4600. This method
adopted to negate the claims of pay parity is not at all rational. Disparity is
allowed to continue further by way of Pay Protection.

The Senior Accountants/Auditors are claiming higher-grade pay on
scientific / historical ground. C&AG and CGA also recommended the higher
Grade Pay in their Memorandums to 7th CPC. Appreciating all these
facts the Senior Accountants/Auditors / Account Assistants (Railways) should
have been granted level 7 in the Pay Matrix by treating the Grade Pay of Rs.
4600 as replacement.

Further, we
would like invite your attention to the statement of the 7 CPC that the
Government had never granted parity in pay scale to Senior Accountant/ Auditor is factually wrong and hence totally
unacceptable.

As
a result of job evaluation done by the Administrative Staff College at
Hyderabad at the instance of III CPC in which Auditors/Accountants has edge
over Assistants grade (of CSS), a solid justification for grant of Pay Scale of
Assistant grade to the Auditor/Accountant post had been laid down.

As such, in 1984, Government themselves upgraded the
Pay Scale of 80% Auditors in the Pay Scale of Assistant grade (425-800) thereby
granting parity in Pay Scales amongst them vide Letter DO No 110141/1/78-EG-I, dated
September 21, 1983 accepted the demand for grant of parity – to 80% of Auditor cadre.
(Copy enclosed as ANNEXURE -I).

The IV CPC not only
clubbed the posts of Auditors of IA&AD and Central Secretariat Assistants
and recommended the pay scale of 1400-2600, but also extended the same pay
scale to Accountants in Indian Audit & Accounts Department and Organized
Accounts which was implemented by the Government with effect from 01.04.1987
vide OM No F.5
(32)-E.III/86-Pt.II, Ministry of Finance, Deptt of Expenditure date 12th
June 1987(Copy enclosed as ANNEXURE - II).

6CPC argued against
disparity in the Pay Scales in the CSS and the field offices and emphatically
recommended that-

“the time has come to
grant parity between similarly placed personnel employed in field offices and
in the Secretariat” and further that “this parity will need to be absolute till
the grade of Assistant” (Para 3.1.3).

As per para 7.56.8 of their
Report, the 6 CPC had observed that because it is recommending merger of pre-
revised pay scales of 5500-9000 & 6500-10500 which will automatically place
Assistants in Central Secretariat and Senior Auditors/Accountants in an
identical pay band and grade pay.

The Government had
implemented the 6 CPC recommendations and granted PB2 Grade Pay of 4200 both to
the Assistants of Central Secretariat and the Senior Auditor/Accountants of
IA&AD &organized Accounts. But subsequently, the Govt. of India vide DOPT
OM No I/I/2008-IC dated 16.11.2009, had granted PB-2 Grade Pay of 4600 to
Assistant of Central Secretariat.

In fact, right from 1984,
the Government decisively maintained parity between Central Secretariat
Assistants and Sr. Accountants/Auditors till it was disturbed in
1990.Government had again restored parity between these two categories of
employees with effect from 01-01-1996 notionally and effectively from
19-02-2003 and this position continued even after implementation of the VI CPC
recommendations. It was disturbed once
again on 16th November 2009. Thus it is factually incorrect to say
that Government never conceded the demand of parity between the Central
Secretariat Assistants and Sr. Accountants/Auditors and no Pay commission
recommended for the said parity between the Central Secretariat Assistants and
Sr. Accountants/Auditors. This observation of 7CPC contradicts its own analysis
and recommendations made in respect to the Defence (Finance) Division vide the
Para 11.12. 137. The approach of the 7th CPC to negate the claims of
parity by bringing down the pay level of Assistants to 6 in the Pay Matrix
instead of granting higher G.P. of Rs. 4600 to Senior Accountants/Auditors is
totally not acceptable. Even in such case the disparity will continue due to
grant of pay protection given to the Assistants who were already in the G.P. of
Rs. 4600. It is requested that the Government reject this negative approach and
grant higher pay of Rs. 4600 to Senior Accountants/Auditors in Organised
Accounts Departments.

“The Commission is therefore of
the view that there is no justification for excluding officers in the Organized
Accounting Departments who are at GP 4800 from this dispensation. It therefore
recommends that all officers in Organized Accounts cadres (in Indian Audit and
Accounts Department, Defence Accounts Department, Indian Civil Accounts Organization,
Railways, Post and Telecommunication) who are in GP4800 should be upgraded, on
completion of four years’ service to GP 5400(PB-2), viz, Pay level 9, in the
pay matrix.”

We therefore,
request that this recommendation may kindly be implemented.

5.Data Entry Operators & Computer Operators

The recommendations given by 7CPC in
paras7.7.21 and 7.7.22 do not fit in Civil Accounts Organization on the ground
that the
EDP grades are not functionally essential after modernization of Civil Accounts organization.
LDCs, Accountants, Senior Accountants, and Assistant Accounts Officers
are efficiently operating the computerized working pattern all over the
organisation without any support of EDP cadres. It is on record that,
Accountant and Sr. Accountants are performing the EDP works and the EDP cadres
particularly the handful of DEOs available only in two departments of Civil
Accounts organization i.e. CBEC and Central Pension Accounting Office are
working as Accountants.

It is also on record that one of the
DEOs of CPAO was converted as Accountant in the year 2000 and posted as
Accountant in one of the Pay and Accounts offices of Ministry of Finance at
Nagpur and by now the incumbent has been promoted as Senior Accountant. (Relevant documents are annexed as
ANNEXURE -III).

Heads of the
Departments of both CBEC and CPAO has suggested for merger of this cadre with
the cadre of Accountant. Accordingly the Controller General of Accounts had
recommended to 6th CPC for merger of the cadre of DEO with the Cadre
of Accountant/ Senior Accountant (Copy
enclosed as ANNEXURE -IV).

The Principal Chief Controller of Accounts, CBEC vide letter
No.Admn./1 (17)9/DEO/2014-15/911 dated 13.10.2014 addressed to the Controller
General of Accounts once again insisted that the DEOs may be converted as
Accountant as there would not any separate data entry work in the organization
within a short time(Copy enclosed as
ANNEXURE -V).

We therefore, request that the Grade-A DEO may be treated as
Accountant at the time of prescribing their revised scale and granted the replacement
pay scale of PB 2 GP 4200 i.e. level 6 pay scale
of Table 5 in Pay Matrix.

6.Stenographer, PS AndSr. PS

Secretarial
staff of Civil Accounts Organisation,
viz. Sr.PS, Private Secretary, Steno Grade-I (Personal Assistant) and
Stenographer Grade-II (Grade ‘D’) are being attached with level of officers in
the rank of Addl.Secretary, Joint Secretary and Director and they are doing
identical and work of similar nature as that of Secretarial staff working under
Addl. Secretary / Joint Secretary / Director level in the Ministry and also
that of Secretarial staff working under C&AG of India (Headquarters).

With
this, we submit that secretarial staff
working in Civil Accounts Organization may be granted the pay scale at par with
Secretarial staff working in the Ministry.

7.Qualification Pay

The
7 CPC vide Para8.9.45 recommended following in respect of additional Pay/increment on passing the SAS
examination - while discussing the Qualification pay - to the Railway accounts
Staff in Paras 8.9.43 & 44
respectively :

“Since the allowance is not indexed to DA, it
is recommended to raise it by a factor of 2.25. The amount will further rise by
25 percent each time DA crosses 50 percent. The nomenclature should be changed
to Railway Accounts Examination Allowance”

This isolated recommendation of clearly
conveys that the 7CPC did not study the memorandums submitted by different
employees Associations of Accounts and audit organizations thoroughly and this
has resulted giving piecemeal recommendations or contradictory recommendations.

The same may please be extended to all wings
within Organized Accounts including IA&AD.

Under
the scheme of Departmental Examination, the UDCs in organized Accounts and
IA&AD used to be placed four stages above the minimum pay on passing the
Examination. This Examination was also extended to Lower Division Clerks who
were graduates. On passing this Examination, the LDC used to be promoted to the
post of UDC (Accountant/ Auditor) with three advance increments. The scheme of
grant of these advance increments was withdrawn by the Government and replaced
by qualification pay after III CPC.

The
qualification Pay is now granted to IA&AD and other organized Accounts
organizations including Railway Accounts employees for different examinations.
As such there is no mention of it in the 7 CPC report. As done in the case of
additional pay/increment on passing SAS examination, the present quantum of
Qualification pay on passing Departmental Confirmatory Examination may also be
increased by a multiplication factor of 2.25 with further rise of 25% when the
DA increase by 50%.

We therefore, request that the
recommendations of 7CPC on granting qualification Pay may kindly be implemented
and made applicable to all organized accounts organizations and IA&AD
uniformly.

It would not be out of place to
mention that no cadre restructuring Group B and C cadres of Civil Accounts organization
has taken place after 1987.

On behalf of the entirety of
employees & officers of Civil Accounts Organisation, we appeal you to consider the above submissions favorably.

We shall also request you to
kindly give an opportunity for oral deposition to the representatives of the
Associations so that they could be able to substantiate and explain the
submissions it has made through this Memorandum.

Copy to Controller General of Accounts, Ministry of Finance
Department of Expenditure, Loknayak Bhawan Khan Market, New Delhi with
reference to his office letter no.A.11019/25/2011/MF.CGA(A)/AICAEA-HQ/413 dated
9th December 2015

As per the decision taken in themeeting of
available leaders of apex JAC on 27th November 2015, a joint
Memorandum to Secretary Department of Expenditure was submitted by the Apex JAC
containing the signatures of representatives of all constituents of Apex JAC
other than Railway Accounts. Efforts are on establish proper liaisonswith
Railway Accounts leadership.

CONGRTULATIONS

We have received reports on observance of demands
day on 15th December 2015 bymany Branches/ Units/ Circles of
Constituents of JAC (especially the Audit and Accounts, Civil Accounts and
Postal Accounts) by holding lunch hour demonstration at respective work spots
and submitting the Resolution to local Head of Offices for onward transmission
to higher authorities. According to the reports received at the apex JAC
headquarters, Demands Day was observed at the stations like Guwahati, Kolkata,
Cuttack, Bhubaneswar, Hyderabad, Cochin, Trivandrum, Madurai, Mumbai, Nagpur,
Lucknow, Jaipur and Delhi.In Delhi local JAC held programmes in AGCR and
Jamnagar House (India Gate) Complexes on 15th and 16th
December 2015 respectively. Com. M. S. Raja, Chairman and Com. V.
Bhattacharjee, Convener apex JAC attended and addressed these meetings in
addition to other leaders of Accounts and Audit.

The apex JAC therefore, congratulates all
thoseBranches/ Units/ Circles which had implemented the programme of Demands
Day on 15th December 2015.

FORMATION/REVIVAL
OF LOCAL JACS’

During the intervening period, two local
JACs i.e. Delhi and Mumbai have been revived. A meeting of the available leaders of Accounts
and Audit organizations was held on 14th December 2015In Delhi in
which Com. Ravinder Kumar from AICAEA and Com. Anil Kumar from CAA has been
elected as Chairman and Convener of local JAC of Delhi respectively. Com. M. S.
Raja, Chairman and Com. V. Bhattacharjee, Convener apex JAC attended the
meeting. Similarly, a new local JAC in Mumbai has also been reported to have
been formed in presence of Com. A. B. Sunil Kumar, Secretary General, All India
Association of Pay and Accounts. Though formal reporting about the formation/
revival of local JACs from both JACs are yet to be received, but we
congratulate the leaders of Delhi and Mumbai for their effort to revive the
local JAC.

We also appeal upon all other
stations/Branches/Units/ Circles to form/ revive local JACs in war footings and
inform JAC headquarters.

NATIONAL
CONVENTION

As decided, the National Convention of the
Accounts and Audit employees and officers’organizations shall be held in
Hyderabad on 10th January 2016.Notice for the same is furnished
overleaf.All constituents arerequested to mobilize required number of
participants from their respective organizations so that the Convention could
be successful and it gives a proper direction to the future movements of
Accounts and Audit Employees and Officers.

With warm greetings,

(V. Bhattacharjee)

Convener

JOINT ACTION COMMITTEE OF

ACCOUNTS
& AUDIT EMPLOYEES & OFFICERSORGANISATIONS

17/2 – C, P & T Quarters, Kali Bari Marg, New
Delhi: - 110001

Email: v.aicaea@mail.com

No: Apex JAC/3/2015 Date:
23rd December, 2015

NOTICE

It is hereby informed to
all concerned that the National Convention of the Accounts and Audit Employees
and Officers shall be held on 10th January 2016 at Hyderabad to
adopt a common approach before the Government of India on the 7th
CPC recommendations and decide about the future course of action for realizing
the long pending issues of the Accounts and Audit Employees and Officers.

The venue for the convention shall be:-

Conference
Hall,

4th
Floor, Nirman Bhawan,

CPWD,

Koti,
Hyderabad

The venue is in the prime
location of the city where large numbers of Central Government Departments including
offices of Civil Accounts are located.

The Convention shall
start at 9.30 a.m. sharp and continue for the day.

With a view to ensure
large participation in the convention, all constituents are requested to
mobilize the representatives from entire country. All National Executive
members, representatives oBranches/ Units/ Circles of the apex JAC
constituents and the Chairman/ Convents of local JAC shall be Delegates.

The constituents and
local JACs are also requested to intimate the estimated number of participants
from their respective organizations to JAC headquarters and any of the
following Comrades of Hyderabad within 2nd January 2016 positively
so that the local JAC could take necessary preparation accordingly.